Course Syllabus
Learning objectives
Tax is an important part of the business environment. With the growth in globalization and the expansion of cross border flow of investments, tax plays a major role in the decision-making process.
Therefore, the ability to accommodate the distinctions of various tax systems around the globe and to understand the policy considerations behind them is what this course is aimed at.
Contents
This course offers a comparative analysis of various solutions that are adopted by several tax systems as a response to increasing common international tax problems of their corporate income tax systems.
First, the basics of international taxation will be explained.
Second, the common core of tax systems of industrialized countries in relation to basic corporate domestic and international tax problems will be identified.
Third, different corporate tax models (and their circulation) among different countries will be analyzed.
Finally, a closer look at the US and Italian corporate tax mechanisms for the resolution of the tax problems discussed earlier in the course will be taken.
In the first part of the course, also the theory and methods of comparative taxation (tax models, formants and common core in corporate tax law) will be illustrated and the economic principles of taxation (efficiency, vertical and horizontal equity, simplicity) will be described so to critically analyze tax policy issues and compare different corporate tax designs.
Detailed program
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Methods and theories of comparative tax law;
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Definition, history and reasons of corporate tax law;
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Role of business in tax law: the reasons behind the taxation of corporate entities; the incidence of corporate taxes; the relationship between corporate and individual level of income taxes; determination of corporate tax base and tax rates;
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The international tax regime: international tax as international law (the benefit principle and the single tax principle);
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The concept of tax residency;
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The concept of source (with a focus on the concept of permanent establishment);
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Taxation of inbound business transactions;
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Taxation of outbound business transactions;
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Taxation of multinationals and cross border investments;
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International corporate tax planning;
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Taxation of reorganizations and cross border reorganizations;
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Prevention of tax avoidance and evasion; enforcement tools: the BEPS project and the EU measures.
Teaching methods
Frontal lessons (didattica erogativa): lectures and practical training on selected topics and issues. Students will also have the possibility do present tax cases. Additional material (cases, new tax law rules, articles) can be recommended to those students who want to study the subject in detail.
Assessment methods
Oral exam about the facts, principles, and issues of internatinal and comparative corporate taxation discussed in the course and also based on the textbook.
Possibility to take a written exam only in the first session at the end of the course.
Textbooks and Reading Materials
R. AVI-YONAH - N. SARTORI - O. MARIAN, Globlal perspective on income taxation law, Oxford University Press, 2011 (excluded chapters 3II and 4).
Sustainable Development Goals
Staff
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Nicola Sartori
